Privacy Policy

Effective January 30, 2012

Claris Healthcare Inc. (“Claris Healthcare” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of the Claris Reflex, which we make available via our website, accessible at ClarisCompanion.com (the “Site”). This Privacy Policy governs your access to and use of the Claris Reflex, and by using the Claris Reflex, you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site. You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Claris Healthcare Terms of Service.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within Canada, the United States or internationally.

How We Collect Your Information

Our primary goals in collecting information are to provide and improve the Claris Reflex, our Site, features and content, to administer your use of the Claris Reflex and to enable users to enjoy and easily navigate the Site.

When you register with us through the Claris Reflex to create an Account and become a Coordinator, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify an individual (“Personal Information”). Personal Information includes, but is not limited to, your name, billing information, and your email address. We use your Personal Information mainly to provide the Claris Reflex and administer your inquiries.
We also collect Personal Information about the individual about whom you create a Member Profile via the Claris Reflex, including, but not limited to, his or her name. Please note that we use this information to provide the Claris Reflex and we will not use this information to contact the individual about whom you create a Member Profile. Additionally, by providing any Personal Information related to the individual about whom you create a Member Profile, you agree that you have obtained the applicable and appropriate permission, releases and consents from such individual to the extent necessary to provide such individual’s Personal Information to Claris Healthcare as part of your use of the Claris Reflex.
We also collect and store any Member Content that you upload, download or access via the Claris Reflex. Such Member Content may contain Personal Information about you or the family member, loved one or other person about whom you create a Member Profile.
Please note that your Coordinator Content is only accessible via the Member Profiles you create via the Claris Reflex.
We also collect the other information that you provide as part of registration and the administration and personalization of your Account (e.g., without limitation, zip/postal code (on its own) and individual preferences) (“Non-Identifying Information”).
Log Data. When you visit the Site, whether as a Member or a non-registered user just browsing (any of these, a “Claris Companion User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, operating system or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Claris Reflex and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, we use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Cookies. Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Claris Reflex. Second, we utilize session ID cookies to enable certain features of the Claris Reflex, to better understand how you interact with the Claris Reflex and to monitor aggregate usage by Claris Companion Users and web traffic routing on the Claris Reflex. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Claris Reflex and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Claris Reflex.
How We Use Your Information

We do not sell, transfer to or share your Personal Information with any other company or organization.
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) to provide the Claris Reflex, complete your transactions, and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your phone number with your address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Claris Companion Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Claris Reflex and to analyze and understand how our Site and Claris Reflex are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
Inviting a Third Party to Access your Account. If you choose to use the Claris Reflex to invite a third party to access a Member Profile created by you, we will ask you for such third party’s name and email address. We will automatically send the third party a one-time email inviting him or her to use the Claris Reflex. We store this information for the sole purpose of sending this one-time email. The third party may contact us at accounts@clariscompanion.com to request that we remove this information from our database.

Phishing. Identity theft and the practice currently known as “phishing” are of great concern to Claris Healthcare. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Information Sharing and Disclosure

Your Use of the Claris Reflex. We will display your Personal Information and Member Content contained in the Member Profile(s) created by you via the Claris Reflex according to the preferences you set in your Account. Any information you choose to provide and make available to third parties via the Claris Reflex should reflect how much you want others to know about you and the individual(s) about whom you create Member Profiles. Please consider carefully what information you disclose in your Member Profiles and your desired level of anonymity. You can review and revise the information contained in your Member Profiles at any time. Through certain features of the Claris Reflex, you may also have the ability to make some of your information (including, but not limited to, Personal Information and Member Content contained in Member Profiles) publicly viewable. We recommend that you guard your sensitive information.

Invited Members. If you choose to invite a third party to become a Member and access one or more of your Member Profiles, such third party will be able to (i) access, view, share, download and distribute the information contained in such Member Profiles, including, but not limited to, your Personal Information and Member Content, and (ii) upload their own Member Content to the Member Profiles, which will then be available to be accessed, viewed, shared, downloaded and distributed, according to the preferences you set for such third party via your Account.

Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Providers. We may employ third party companies and individuals to facilitate our Claris Reflex, to provide the Claris Reflex on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, payment processors, web analytics and improvement of the Claris Reflex’ features) or to assist us in analyzing how the Claris Reflex are used. These third parties have access to your Personal Information and Member Content only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement. Claris Healthcare cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Claris Healthcare or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Business Transfers. Claris Healthcare may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting Your Information

All Members may review, update, correct or delete the Personal Information and Member Content in their Account and Member Profiles created by such Members by contacting us or via the Member Profile section of the Claris Reflex. If you delete all such information, then your Account may become deactivated. If you would like us to delete your Account in our system, please contact us at accounts@clariscompanion.com with a request that we delete your Personal Information and Member Content from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Data Retention

We will retain the information you provide via the Claris Reflex for as long as your Account is active or as needed to provide you with the Claris Reflex. We may retain and use the information you provide via the Claris Reflex, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to delete your Account, please see the section titled “Changing or Deleting Your Information” above.

Security

Claris Healthcare is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Claris Healthcare transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Websites

Our Site may contain links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children

The Claris Reflex are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at accounts@clariscompanion.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.